CBSA has not finalized all of the processes and policies for CARM, but here are a few items and importers can do now to prepare for CARM’s key changes to importers: financial security, payment processes, and CCP registration.
Step 1: Secure a surety bond (Customs Bond)
There are several key changes to what may be your usual operations as an importer. One of these changes is that you can no longer rely on your customs broker’s financial security for release prior to payment (RPP).
You’ll need to provide your own financial security through either a surety bond or a cash deposit.
There will be approximately 300,000 importers and trade chain partners involved in the customs bond process to prepare for CARM Release 2. To avoid backlogs, delays, or the inability to get a bond before the go live date for CARM, obtain and register your bond with CBSA now. Cole can supply a bond, EMAIL US.
Step 2: Review your payables process
CBSA has very specific guidelines for when payments must be made. On time payment is critical under this new system.
In most cases, the payment terms/timelines currently have in place with your customs broker will not be the same as the required CBSA timelines.
Importers need to review their payables process and payment timeframes to:
- Confirm your bank is set up to receive and transmit payments on behalf of CBSA
- Ensure your payment process is set up to meet the payment deadlines mandated by CBSA, including allowing sufficient timelines for any internal approvals
- Confirm any applicable third-party payment companies, at home or offshore, have the ability to manage this process for you. This process is crucial to the ongoing movement of your goods across the border. You may need to reconsider these partners’ involvement with customs payments to bring this process back in-house so you have direct control of the process or to centralize to one servicer.
- Non-resident importers need to establish a Canadian bank account to support this payable process, as all payments must be in Canadian dollars. Many of the main US banks are not yet set up electronically with CBSA.
Step 3: Register your Business in the CCP
The CCP is now available for importers to register their business. Cole continues to monitor CBSA's program updates and is developing procedures to assist you with the smoothest transition possible.
Items to consider before registering in the CCP:
- Is the legal entity information on file with CBSA accurate?
- Refer to the recent correspondence from CBSA or your business CRA account to verify the legal name, address and contacts on file are current.
- Who will act as your primary Business Account Manager (BAM) responsible to register and delegate access in the CCP? Who will be the alternate account holder in your organization?
- The BAM does not have to be the officer of the company, this could be assigned to who manages the organization’s trade information or CBSA payments.
- We would recommend the person in your organization who interfaces with your customs broker act as the primary and someone in your accounts payable department that will manage your daily and monthly statements and payments to CSBA act as the alternate.
Once your organization has discussed CARM and have assigned the primary Business Account Managers, prepare for the CCP registration process by gathering information to validate your user account to your business. Registering a Business - Information Sheet (English), Information Sheet (French)
Many importers will need support from their brokers for the financial information required, Contact our CARM Registration Support team for inquires or assistance in completing the onboarding process. Find additional information about registration here Registering in the CARM Client Portal (CCP) and/or find tutorials on CARM's Client Portal on YouTube.
Step 4: Decide how your business will manage your service providers
CBSA will require importers to confirm (within the CCP profile) which customs broker(s) their company uses, and this could include any couriers.
Importers need to decide:
- The level of information and features each broker will have access to, and
- What each third-party service provider will manage on your company’s behalf.
For importers with multiple brokers, this may present a significant challenge.
Some questions to consider:
- Does your company have a primary broker that manages the bulk of your business? Will they have access to all your import information or just what they handle?
- Does your company use consultants that will need access to import records for one or all of your brokers?
- How will your company manage changes in brokerage firms and other service providers and changes to delegation options?
- Will you need to consolidate some of your customs business or service providers to reduce the number of firms your company needs to manage?
- What services within the portal will your company manage internally and what will be managed by your service provider?
Information relating to CCP third-party delegation and visibility is available. Learn more
Before approving any third-party access requests or visibilities in your CCP, be sure to confirm who is requesting access and what functions they currently perform in your CBSA processes.
Step 5: Stay informed
The development and release of this new program is on a very rapid timeline. Although design and policy have not yet been finalized by CSBA, the agency has released information about many of CARM’s upcoming features, requirements, and functions.
Keep in mind these may be subject to some change before the full program launches. Please visit this site regularly or subscribe to our CARM Updates.